Despite claims that AWEX has undertaken broad industry consultation, AWGA chairman Martin Oppenheimer says that AWGA was not involved at all in the development of this proposed declaration.

"There are significant flaws in this proposed National Wool Declaration, importantly relating to the definition of mulesing and the inclusion of clipped wool as unmulesed," Mr Oppenheimer said.

AWGA has three questions that it says must be answered:

1. Why is the AWEX definition of mulesing different to the gazetted National Code of Practice for the welfare of sheep?

2. Why is clipped wool included with unmulesed wool?

3. Why is Australian Wool Innovation (AWI) selling mulesing clips?

The gazetted National Code of Practice for the welfare of sheep is the official government and industry position on mulesing ( see www.publish.csiro.au/nid/22/pid/5389.htm).

AWGA says that section 9.5 of the National Code of Practice has the definition of mulesing as "the removal of skin from part of the breech area", but in contrast the new AWEX definition is the "removal of skin from the tail and/or breech region of a sheep using shears".

AWGA suspects that the change of mulesing definition from the National Code of Practice by AWEX, to include "shears", came about under pressure from AWI to accommodate AWI’s research project clip mulesing technology.

"Unfortunately AWEX have made a major mistake with the inclusion of clipped wool with unmulesed wool, and may threaten the commercial value of this new market segment," Mr Oppenheimer said.

"Significant retailers have chosen not to accept clips, but how can they differentiate clipped wool from unmulesed wool now?

"AWI should get the mulesing clips to market via commercial partners, but not get involved in selling them.

"According to AWI the cost will be $1.50 to $2.00 per head for the plastic clips, with biodegradable clips expected to be more expensive. The commercial viability of this technology will be interesting."

Mr Oppenheimer said growers who protect their sheep with surgical mulesing are adopting pain relief at $0.63 per head for lifetime protection, and in the longer term are looking at breeding sheep that are less susceptible to breech strike.